Writing for the Virginia Law Review, Judge Wilkinson of the U.S. Court of Appeals for the 4th Circuit says that Heller, like Roe, was disrespectful of legislative judgments, has hurled courts into a political thicket of fine-tuning policy in interminable litigation and traduced federalism. Furthermore, Heller exposed “originalism” — the doctrine that the Constitution’s text means precisely what those who wrote its words meant by them — as no barrier to “judicial subjectivity.”

Yes, except the Second Amendment is right there, staring at you in the face in the Bill of Rights. It’s not to be found emanating from any penumbras.